Telephone log

March 17, 2004

Conversation between Margaret Sheppard, EPA SNAP Program and Mr. Jeff
Gartline, FAA (Tel 425-227-2136)

I called Jeff Gartline to find out if regulations on adhesives using
n-propyl bromide would create a problem for the Federal Aviation
Administration or for the aircraft-building industry.

Mr. Gartline explained that FAA requirements did not specify a specific
adhesive in cushions used on aircraft.  Rather, there is a performance
test for flammability of materials used in the aircraft passenger cabin.
 There are two levels of requirements.  Aircraft cushions must meet
requirements for flotation and for flammability at 14 CFR part 25.  In
the past, foam fabricators have said that they couldn’t use
water-based adhesives to meet the requirements because it didn’t
provide sufficient seal.  FAA has granted an exemption from the
lower-level requirement for one company when using the water-based
adhesive, provided that they still meet the higher-level requirement.  

This industry has gone through the process of replacing
1,1,1-trichloroethane with methylene chloride and then with water in
adhesives.  However, the water-based adhesive didn’t pass the
flammability testing by “the company or independent” testers.  

I asked Mr. Gartline if there would be a problem for FAA or for the
industry if EPA were to restrict or even ban the use of n-propyl bromide
as a solvent in adhesives.  He indicated that it would be possible for
other companies to qualify for the partial exemption from the
lower-level requirement, as well.

